Privacy Policy

• What personal information we have and how we get it; 
• How we can and cannot use it;  
• Who we can share it with; and  
• About your privacy rights and how the law protects you.  

Purpose

• Any data you may provide when applying to enter, or prior to entering into, a contract with us; 

• Your use of our website, mobile device applications, web chat, secure messaging and or face identification, verification and recognition technology; 
• Emails and or letters; 
• When you talk to us including recording of calls and notes we make; 
• Customer surveys; 
• Your taking part in our competitions and or promotions. 

Controller 

Contact details 

Third party links 

Using our online calculators and decision tools   

• Your full name and title; 

• Your home address, correspondence address (where different from your home address), email address, home and mobile telephone numbers. 
• Your address history;  
• Your date of birth and/or age;   
• Identification documents including document type, date of expiry and country of issue;  
• A short video/face identification, verification and recognition technology of yourself when you set up an account with us via a Secure Communications Network (for more information, please see the end of this section);  

• Your e-signature;  
• Your nationality, if this is necessary for us to comply with our legal and regulatory requirements;  
• Records of how you have contacted us and, if you get in touch with us online, details such as your mobile phone location data, IP address and MAC address;  

• Details of shareholdings, prominent functions, directorships and/or employment including for instance your occupation, salary, employer and length of service;  
• Where relevant, information about any co-director or guarantor which you provide in any application;  
• Information about your employment status including whether you are employed/self-employed, retired or receive benefits;  
• Performance of your mortgage; 
• Where relevant, in relation to adverse credit, information about creditors and supporting references;  

• Bank account and payment card details. 

• Information about your occupier status, such as whether you are a tenant, live with parents or are an owner occupier of the property in which you live at the time of your application;  
• Information which is relevant for your residency and/or citizenship status, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK;  

• For residential customers, your marital status, family, lifestyle or social circumstances if relevant to the mortgage product (e.g. the number of dependents you have or if you are a widow or widower). 

• Personal information which we obtain from Credit Reference Agencies (CRAs) and Fraud Prevention Agencies (see the section on ‘Fraud Prevention Agencies’ below);   
• Some special categories of personal data such as about your health or if you are a vulnerable customer (more details below). 

• Details of your services with us including for instance application information, (including on-line applications) affordability assessments, (including on-line calculators, tools and guides) credit history, customer ID number, account number, account balance, account history, security or collateral held by us, and details relating to any other signatories and/or guarantors;  
• Security identifiers including for instance mother’s maiden name; 
• Your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. 

• Information about how you use our website, mobile device applications, secure messaging, and webchats for products and services. 
• Details about payments to and from you and other details of products and services you have purchased from us. 

• Information you have provided in receiving marketing from us and/or companies within the Pepper Group and your communication preferences. 

Aggregated Data 

If you fail to provide personal data 

Commercial applicants, joint applicants, guarantors and powers of attorney   

Direct interactions 

We will generally collect your personal information from you directly, including application forms, letter and or email correspondence, secure messaging, telephone, or via our website/mobile device applications. If you are introduced to us by a broker or other intermediary, we will obtain some personal information about you indirectly from them when they introduce you to us.   

Open Banking 

Information we use when connecting to ‘Open Banking’

Consent to connect to Open Banking. With your permission, we access specific details about accounts you hold with other banks to help us make lending decisions. If you do not give us consent to access an account, this may affect the service we are able to offer you. 

Information we get from banks. When you give us consent to access details about accounts you hold with banks so we can make lending decisions, we collect: 

• Full legal name of any account holders and status (open/closed) 
• your account number, sort code, 
• your account balance 
• details of all transactions going in and out in the last 12 calendar months. 

The information that you provide will also allow us to analyse bank transaction data to assist with credit risk evaluation. 

Third party and publicly available sources 

In addition, we may obtain your personal information from other sources such as Fraud Prevention Agencies, Credit Reference Agencies, your employer, landlord, other lenders, HMRC, DWP, publicly available directories and information (e.g. telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies.  

Some of the personal information obtained from Credit Reference Agencies will have originated from publicly accessible sources. In particular, Credit Reference Agencies draw on court decisions, bankruptcy registers and the electoral register (also known as the electoral roll). We explain more about Credit Reference Agencies below. We have also mentioned above in the lists of personal information that we process some of the Credit Reference Agencies’ other sources of information (which are our own source of information too).    

When a broker or other intermediary processes your personal information on our behalf, this privacy policy will apply and you should contact us to exercise your rights under data protection laws. When a broker or other intermediary processes your personal information as a data controller in its own right, its own privacy policy will apply and you should ask them for a copy if you do not have one by the time you are introduced to us.  

We may also obtain Technical and Profiling Data (defined in section 3) (by way of example) from the following third parties: 

• analytics providers [such as Google based outside the UK];  
• advertising networks [such as Facebook, Google, Bing based outside the UK];  
• search information providers [such as Google and Bing based outside the UK] 

and other third party analytics and or search providers. 

We may also obtain Identity Data in the form of facial verification and recognition technology to verify identity.  

Using Face Identification, Verification and Recognition Technology 

You can apply for some of our products and services using a face recognition session from your mobile device to verify your identity and contact details. 

If you use our face recognition service both the images and the audio will be recorded and may be used for training and monitoring services. We’ll use any personal data captured about you for the performance of a contract or/with a view to entering into a contract with us as well as for our legitimate interests for good governance, accounting, managing and auditing our business operations, and to monitor emails, calls other communications in relation to dealings with us. 

For your own privacy and protection please ensure that your location doesn’t include items and images that you don’t wish to be recorded. 

Secure Instant Messaging   

We in our sole capacity or in conjunction with a broker or other intermediary engaged by us, may process your personal information to set up and administer your account. The secure instant messaging platform will be used to:  

• provide (from us to you or you to us) correspondence, data, documentation and personal information as part of joining and applying for a mortgage and prior to and entering into a contract with us;  

• provide images of documentation and yourself to support our identification checks, fraud and money laundering controls; and   
• to discuss any queries about your account.   

Electronic Signatures  

We utilise electronic signature applications to enable contracts and notices to be signed.  In utilising such tools our employees, brokers acting on our behalf, third party suppliers and you may provide limited personal data for the purposes of:  

• business execution and in particular for the conclusion and execution of agreements between us and you;  
• for compliance with legal or regulatory requirements including litigation and defence of claims; and  
• for the prevention, detection and investigation of fraud.   

Automated technologies or interactions 

As you interact with us, we will automatically collect some Technical and Profile Data about your equipment, interactions, voice analysis, browsing actions, usage data and patterns. We collect this personal data by using cookies [server logs] and other similar technologies.  

We may also receive Technical Data about you if you visit other websites employing our cookies. Please see section 16 ’Cookies’ below for further details. 

Purposes for which we will use your personal data

Much of what we do with your personal information is not based on your consent, instead it is based on other legal grounds. For processing that is based on your consent, you have the right to take back that consent for future processing at any time. You can do this by contacting us using the details above. The consequence might be that we cannot send you some marketing communications or that we cannot take into account special categories of personal data such as about your health or if you are a vulnerable customer (but these outcomes will be relevant only in cases where we rely on explicit consent for this).    

We will tell the broker or other intermediary who introduced you to us that you have withdrawn your consent only if it is our data processor (this means an organisation who is processing personal information on our behalf) or if we are required to do when you exercise certain rights under data protection laws. You should make sure to contact them directly to withdraw your consent for what they do with your personal information as a data controller in their own right.   

To comply with payment services regulations, we have to share some of your personal information with other payment service providers in some circumstances such as when you ask us to share information about your account with them. Whilst those payment services regulations mention ‘consent’ for this, ‘consent’ in that context does not have the same meaning as ‘consent’ under data protection laws. The legal grounds which may be relevant to this are compliance with our legal obligations, performance of our contract with you, our legitimate interests, or a combination of these. This is why if you ask to withdraw consent from what we do with your personal information, we may still have to hold and use your personal information where we need to have it in relation to the payment services regulations.

We work hard to protect your personal data. We use both technical and procedural methods to maintain the integrity and security of our databases, encryption for data transfer, firewalls and restricted access to data. 

The safety and security of your data also depends on you. You should never share your account information such as your password or login with anyone else.  If you believe anyone has unauthorised access to your account you should contact us promptly.

What do we do with your data and who do we share it with?

• Internal third parties including members of the Pepper Group;  
• External third parties such as: 
• Your guarantor (if you have one);   

• Joint account holders, co-directors, trustees and beneficiaries and any person with power of attorney over your affairs (in each case only if relevant to you);  
• Credit reference agencies and fraud prevention agencies (see section 10 below); 
• Other payment services providers such as when you ask us to share information about your account with them;  
• Other account holders or individuals when we have to provide your information to them because some money paid to you by them should not be in your account;   
• The broker or other intermediary who introduced you to us;  

• Our legal and other professional advisers, auditors and actuaries;  
• Financial institutions and trade associations;   
• Governmental and regulatory bodies (including but not limited to) such as HMRC, the Financial Conduct Authority, the Financial Ombudsman Service, the Information Commissioner’s Office and under the Financial Services Compensation Scheme;   
• Tax authorities who are overseas for instance if you are subject to tax in another jurisdiction we may share your personal information directly with relevant tax authorities overseas (instead of via HMRC);   
• Other organisations and businesses who provide services to us such as debt recovery agencies, back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions;  

• Insurers of any asset securing or proposed to secure your liabilities  
• Buyers, counterparties, rating agencies and other relevant parties and their professional representatives as part of any actual or potential restructuring or sale of any or all of our assets (including by way of a securitisation or similar transaction); and 
• Market research organisations who help us to develop and improve our products and services. These firms may get in touch to ask you for your opinions and feedback. Sometimes these firms will combine what you tell them with data from other sources to study it. They will use this to produce reports and advice that help us understand our customers’ point of view, so that we can improve the way we work as a business 

We are based in the UK but sometimes your personal information may be transferred outside the UK or the European Economic Area. If it is processed within Europe or other parts of the European Economic Area (EEA) then it is protected by European data protection standards. Some countries outside the EEA do have adequate protection for personal information under laws that apply to us. We will make sure that suitable safeguards are in place before we transfer your personal information to countries outside the EEA which do not have adequate protection under laws that apply to us.     

Where the borrowing is on behalf of a company, we will obtain a Credit Safe Report; this will involve the transfer of personal information outside of the EEA.  We confirm that there are adequate safeguards in place to protect the transfer of your personal data outside of the EEA.  

For more information about suitable safeguards and (as relevant) how to obtain a copy of them or to find out where they have been made available you can contact us using the details above.  

Credit reference agencies 

• Assess your, or where the borrowing is on behalf of a company, your company’s creditworthiness and whether you/it can afford to take the product;  

• Verify the accuracy of the data you have provided to us;  
• Prevent criminal activity, fraud and money laundering;  
• Manage your account(s);  
• Trace and recover debts; and  
• Ensure any offers provided to you are appropriate to your circumstances. 

Fraud prevention agencies 

If your application is unsuccessful  

• The right to be informed about your processing of your personal information;  
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;  
• The right to object to processing of your personal information;  
• The right to restrict processing of your personal information;  

• The right to have your personal information erased (the “right to be forgotten”);  
• The right to request access to your personal information and to obtain information about how we process it;  
• The right to move, copy or transfer your personal information (“data portability”);   
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.  

In this section monitoring means any listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person face to face meetings and other communications.   

We may monitor where permitted by law and we will do this where the law requires it. In particular, where we are required by the Financial Conduct Authority’s regulatory regime to record certain telephone lines or in person meetings (as relevant) we will do so.  

Some of our monitoring may be to comply with regulatory rules, self-regulatory practices or procedures relevant to our business, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures, to have a record of what we have discussed with you and actions agreed with you, to protect you and to provide security for you (such as in relation to fraud risks on your account) and for quality control and staff training purposes. 

Some of our monitoring may check for obscene or profane content in communications.  

We may conduct short term carefully controlled monitoring of your activities on your account(s) where this is necessary for our legitimate interests or to comply with our legal obligations. For instance, where we suspect fraud, money laundering or other crimes.   

Telephone calls, written communication, emails (including mobile device applications, secure messaging, webchats) and/or in person meetings between us and you in connection with your application and/or your account(s) may be recorded to make sure that we have a record of what has been discussed and what your instructions are. We may also record these types of calls for the quality control and staff training purposes.  

This section is relevant where we make decisions about you using only technology, and where none of our employees or any other individuals have been involved in the process. For instance, in relation to transactions on your account(s), payments into your account(s) from other providers, and triggers and events such as account opening anniversaries and maturity dates. We may do this to decide what marketing communications are suitable for you, to analyse statistics and assess lending risks.

We can do this activity based on our legitimate interests (and they are listed in the section about legal grounds above) only where the profiling and other automated decision making does not have a legal or other significant effect on you. In all other cases, we can do this activity only where it is necessary for entering into or performing the relevant contract, is authorised by laws that apply to us, or is based on your explicit consent. In those cases, you have the right to obtain human intervention to contest the decision (see ‘rights in relation to automated decision making which has a legal effect or otherwise significantly affects you’ below). Profiling for direct marketing can mean there is a separate right to object (see ‘right to object’ above).  

We may use your home address, business address, phone numbers, email address and social media accounts (e.g. Facebook or LinkedIn), to contact you. We may also use “cookie data” from visits to our website to market to you across Google and other search engines, certain websites, social media and other messaging platforms. In all instances we will only ever market to you according to your marketing preferences. This means we do this only if we have a legal ground which allows it under data protection laws – see above for what is our legal ground for marketing. You can stop our marketing at any time by contacting us, by following the instructions on how to do that in the marketing email or other communications we send to you. 

• gather information about your computer in order to assist us in serving content to you in the most appropriate manner;  
• help us better understand your journey for example how you arrived at our site, and on what page you left our site; and   
• capture generic information, such as your geographical location. 

What are cookies? 

• Essential cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. 
• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. 
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.  

Potential consequence of allowing cookies 

• Google Analytics
• Facebook
• You can opt out of Google or Facebooks use of cookies or device identifiers by visiting Google’s Ads Settings or Facebook’s Ads Settings. Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings.

How do I change my cookie setting?

We may also use cookies for re-marketing or re-engagement purposes. Our website and other technologies uses the re-marketing function of third-party sites including, but not limited to, Google Ads and Facebook.  This feature is designed to show interest-based ads to visitors to our site.  What this means is that your browser will save the cookies that allow you to be recognised when visiting websites belonging to third parties such as the Google Ad network and Facebook.   This could mean that we advertise to you if you haven’t completed a task on our site, for example, using the contact form to make an enquiry, or if you fit a similar profile to our site visitors.  This could be in the form of an advertisement on the Google search results page, a site in the Google Display Network, or somewhere on Facebook (or another social media site).  Third-party vendors, including search engines and social media sites, use cookies to serve ads based on past visits to our website.  Any personal information collected will be used in accordance with our privacy policy, as well as the relevant third party’s privacy policy.  

You can opt out of a third party’s (such as Google’s or Facebook’s) use of cookies or device identifiers by adjusting your ad settings on the relevant site.  Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings. 

You will see in the body of this privacy policy that we have mentioned that we share your personal information with Fraud Prevention Agencies and Credit Reference Agencies. They require us to pass on to you information about how they will use your personal information to perform their services or functions as data controllers in their own right.  These notices are separate to our own.  We do need to share these with you. Here are links to the information notices of four Credit Reference Agencies that we use:

• Callcredit
• Equifax
• Experian
• Creditsafe 

Further details of how your information will be used by us and fraud prevention agencies, and your data protection rights, can be found by accessing the following link: Fair Processing Notices for Cifas’ Databases | Cifas 

It is important to us that your personal information is up to date. We will take reasonable steps to make sure that your personal information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.